The Medicare Part B program allows several services provided by registered dietitian nutritionists (RDNs) and nutrition professionals to be offered via telehealth. These services include:
- Medical nutrition therapy (MNT), individual and group
- Diabetes self-management training (DSMT), individual and group
- Intensive behavioral therapy for cardiovascular disease (must be billed by the primary care provider)
- Behavioral counseling for obesity, individual (must be billed by the primary care provider)
- Annual wellness visit (must be billed by the primary care provider)
When providing these services via telehealth, all of the CMS requirements for such services still must be met. This means the beneficiary must meet the eligibility criteria for the service, the provider delivering and billing for the service must be eligible to do so, the service must be delivered in the setting defined by CMS, and all other billing guidelines must be followed. View the Academy's page about CMS coverage and billing guidelines for each of these services.
According to CMS requirements, the patient receiving the service must be present and participate in the telehealth visit. Additionally, the telehealth services must include use of an interactive audio and video telecommunications system and must be in “real time.” Therefore, telephone calls, images transmitted via facsimile machines and text messages (email) without visualization or stored and delayed transmissions of images of the patient do not qualify as telehealth services.
For Medicare payment to occur for telehealth services, the practitioner must be licensed to provide the services under state law. According to the Medicare MNT benefit regulations, all licensed or certified (where applicable) RDNs are eligible to become Medicare MNT providers. Therefore, RDNs who live in states with or without licensure laws are recognized to provide telehealth MNT service. However, if a Medicare beneficiary receives individual MNT via telehealth in another state from where the RDN’s office is located, the RDN must be licensed in both states. In states where there are no licensure laws, the RDN credential is sufficient to provide the telehealth service. Visit the Academy's page on licensure and telehealth for more information. .
Originating Site and Distant Site Criteria
CMS has indicated that Medicare beneficiaries may only receive the MNT or DSMT service(s) from an "originating site" located in a rural Health Professional Shortage Area (HPSA) or in a county outside of a Metropolitan Statistical Area (MSA). (View more information on the Bureau of Census classification of non-MSA counties; view a list of HPSAs.) The term originating site means the location of an eligible Medicare beneficiary at the time the service being furnished via a telecommunications system occurs. Originating sites authorized by law include:
- The offices of physicians or practitioners;
- Critical Access Hospitals (CAH);
- Rural Health Clinics (RHC);
- Federally Qualified Health Centers (FQHC);
- Hospital-based or CAH-based Renal Dialysis Centers (including satellites);
- Skilled Nursing Facilities (SNF);
- Community Mental Health Centers (CMHC)
- Renal Dialysis Facilities
- Home of beneficiaries with End-Stage Renal Disease (ESRD) getting home dialysis
- Mobile Stroke Units
The term "distant site" means the location where the physician or practitioner providing the professional service is located at the time the service is provided via a telecommunications system.
Exceptions to Medicare telehealth services
CMS is currently undertaking a federal telehealth demonstration project in Alaska and Hawaii where services may be provided in locations that may not be rural or non-MSA, and where other telecommunication equipment may be used.
The payment amount for the professional service provided via the telecommunications system by the registered dietitian nutritionist at the distant site is equal to the current fee schedule amount for MNT or DSMT services based on the RDN's geographic location. The beneficiary is responsible for any unmet deductible amount and applicable coinsurance or copayment. Since January 1, 2011, copayments and deductibles are waived for MNT, but not DSMT services. The same CPT and G codes are used to bill for the services. To indicate that the billed service was furnished as a telehealth service from a distant site, submit claims for telehealth services using Place of Service (POS) 02: Telehealth: The location where health services and health related services are provided or received, through telehealth telecommunication technology. Medicare no longer requires use of the GT (via interactive audio and video telecommunications system) modifier on claims (exception: Critical Access Hospitals billing under Optional Payment Method II). For telehealth services provided as part of Medicare demonstration projects in Alaska and Hawaii, the GQ (via synchronous telecommunications system) modifier must be used.
In addition, the originating site, where the beneficiary receives the service, is eligible to receive a facility fee as described by HCPCS code Q3014. This fee is established annually by CMS and can be found in the Medicare Physician Fee Schedule. The beneficiary is also responsible for any unmet deductible amount and Medicare coinsurance for the originating site fee. Once again, since January 1, 2011, copayments and deductibles are waived for MNT, but not DSMT services. For more information on payment methodology for originating sites, refer to the Medicare Benefit Policy Manual (see below).
Online Assessment and Management Services
While not technically classified as a telehealth service under Medicare Part B, RDN Medicare providers may use the following G codes with their Medicare Part B beneficiaries after an initial MNT encounter:
- G2061: Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes
- G2062: Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes)
- G2063: Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes
Written or verbal informed consent must be obtained and documented in the medical record prior to providing the service. Consent can be done once a year. The service is initiated by an established patient and must be delivered through a HIPAA-compliant, secure platform. If the patient generates the initial inquiry within 7 days of an MNT encounter and the inquiry is related to the same problem, then the RDN cannot separately report these codes. Learn more by reading the November 2019 issue of the MNT Provider newsletter.